Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Reopening of assessment u/s 147 - reassessment proceeding was triggered based on a Tax Evasion Petition (TEP) - Bald assertions in the TEP that the petitioner had claimed bogus expenses towards salary and other heads, in our view, was not sufficient for commencement of the reassessment proceeding under Section 147 read with Section 148 of the Act. - HC
Reopening of assessment u/s 147 - reassessment proceeding was triggered based on a Tax Evasion Petition (TEP) - Bald assertions in the TEP that the petitioner had claimed bogus expenses towards salary and other heads, in our view, was not sufficient for commencement of the reassessment proceeding under Section 147 read with Section 148 of the Act. - HC
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